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Posted on Mon, Aug 31, 2009 : 11:13 p.m.

University of Michigan coach Rich Rodriguez sued for defaulting on real-estate deal

By Dave Birkett

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University of Michigan football coach Rich Rodriguez is being sued for defaulting on a real-estate loan to build high-end condominiums in the shadows of Virginia Tech’s Lane Stadium.

One of five guarantors for a proposed 80-condominium gated community called The Legends of Blacksburg, Rodriguez and his partners allegedly owe Nexity Bank $3.9 million, including interest and penalties.

Rodriguez was served a summons and complaint in his football office at 5:27 p.m. on Aug. 24, court papers show. Michigan practiced earlier in the day.

According to court filings, The Legends of Blacksburg, LLC, signed a loan promissory note for $26.1 million in September 2007, when Rodriguez was coach at West Virginia.

In an addendum a year later, the loan obligation was reduced to $3.6 million. It matured in May and is collecting interest at $933 a day, according to complaint.

According to the Web site vatechcondos.com , the proposed development features one-, two- and three-bedroom condos, all with views of Lane Stadium and within walking distance of Virginia Tech’s athletic complex.

The units start at $350,000 and range from 800- to 1,600-square feet, according to the Web site, which indicated that 52 of the 80 condos are reserved.

Rodriguez’s financial advisor, Mike Wilcox, released a statement through Michigan spokesperson Dave Ablauf late Monday, saying Rodriguez is the victim of a real-estate Ponzi scheme.

“Several other coaches and prominent individuals are involved in this transaction that was initiated in 2004,” Wilcox said. “This is a personal issue, and as Coach Rodriguez’s financial advisor, I and his legal counsel will be handling this matter moving forward. We are evaluating legal actions and solutions since the promoter of the scheme is currently awaiting trial on criminal charges.”

The deal took place in December 2004, prior to Wilcox's becoming Rodriguez's advisor and legal counsel, according to Ablauf.

Along with Rodriguez, Ronald West, Floyd Elliott, Lamar Greene and Jeffery Greene are named defendants in the suit filed Aug. 13 in a U.S. District Court in Spartanburg, S.C.

Virginia Tech coach Frank Beamer, who is not named in the suit, appears on the Web site encouraging “fans, alumni and supporters” to “join me and live among the legends of Virginia Tech athletics.”

Dave Birkett covers the University of Michigan football team for AnnArbor.com. He can be reached at davidbirkett@annarbor.com

For more information, click on the PDFs of the court documents in this case attached below:

Plantiff Exhibit A.pdf

Plantiff Exhibit B.pdf

Comments

weaverb2

Wed, Sep 2, 2009 : 8:24 a.m.

As a WVU alum, my observation on RR is that he is and has been a victim of bad advice...from his attorney, his agent, and his wife...the fact that he is involved in a real estate deal "gone south" is just another example of this bad advice....RR is a good coach but does have a big ego....I believe the current allegations regarding improper practices are nothing more than a witch hunt...his former WVU players have come out publicly in his defense saying he had only their best interests in mind and they know of no circumstances where he broke the rules....I wish you guys the best with RR...personally, I am glad he is no longer in Morgantown....he is a great coach but his ego created internal problems within the University...and it appears he is still releying on the same group of incompetent advisors....too bad...

stevieboy

Wed, Sep 2, 2009 : 12:57 a.m.

Who Cares?!!!!! What this got to do with Football?

RASWVU

Tue, Sep 1, 2009 : 5:44 p.m.

The use of the phrase "Ponzi Scheme" is an obvious attempt by the Rich Rodriguez camp to obtain sympathy. This is not a new tactic. Remember his lawyer, Robon, comparing Rich's stay at WVU with slavery. "Legends of Blacksburg" was not some nonexistant project sold to unwitting investors. It aquired property next to Lane Stadium, evicted college students residing in an apartment building that existed on the site and demolished that building. Then the economy went South and construction was never started. This was a speculative real estate deal that fell though, nothing else. Yet Rich's camp throws out a term that is charged with images of Bernie Madoff swindling poor old Jewish grandmothers out of their retirements, savings, and homes in an attempt to secure aympathy for Rich. We have seen this act before.

OSUbeBetter

Tue, Sep 1, 2009 : 5:11 p.m.

Rich rod has absolutely no idea what it means to read and sign a contract does he? I mean hes a total moron. Question, A Ponzi scheme would be an investment based on nothing (A Lie), but The Legends of Blacksburg is a real thing, how is that a Ponzi? just because an investment doesn't turn out doesn't make it a Ponzi Scheme.

wvuweirton

Tue, Sep 1, 2009 : 4:58 p.m.

Keep defending RR.... Will see how you feel at the end of the season... Remember what RR said about his lawsuit with West Virginia --- I'm right, they are wrong, he said that until UM and RR ended up paying WV the entire 4 million dollars lawsuit against him... According to sources, neither RR or UM wanted to end up in court under oath - that's why both UM and RR cried Uncle... MAYBE IF RR WAS MORE CONCERNED WITH UM FOOTBALL PROGRAM LAST YEAR INSTEAD OF HIS WV LAWSUIT, UM WOULDN'T HAVE ENDED UP WITH IT'S WORST SEASON EVER.... NOW WE GO AGAIN WITH HIS NEW LAWSUIT AGAINST HIM - MAYBE UM CAN PAY THIS ONE OFF ALSO!!!

Bellevillekevin

Tue, Sep 1, 2009 : 4:39 p.m.

How is this a ponzi scheme? The market went south, they are not going to make as much of a profit, and they are taking a loss. I'm sure if it performed as they thought, they would not be offering the bank additional money. Calling everything a ponzi scheme is like Kwame Kilpatrick calling everything 'racist.' It's a buzz word. This Wilcox guy is trouble and RichRod should dump him. He has no real education, and is a flim flam man.

81wolverine

Tue, Sep 1, 2009 : 3:25 p.m.

This is simply a personal business issue for Coach Rodriguez. Nothing more. It has nothing to do with his coaching the football team. Let's put it in perspective, shall we? I'm getting completely fed up with all the piddly crud being dredged up by so-called writers and reporters with the sole intent of attacking RR's personality and integrity. Further, I would venture a guess that almost no one commenting on this website have ever met him or have any personal knowledge of his integrity and honesty. So, instead of whining about non-issues, let's just move on and support the coach and the team. For crying out loud, let him do his job without nitpicking every single thing he says or does. Just like none of us are perfect, neither were Bo, Moeller, or Carr. The difference is today, people in the media and others wasting countless hours on blogs and web forums have nothing better to do than to say disparaging things about the new coach. If RR had went 9-3 last year instead, I'm guessing we wouldn't be hearing too much bitching right now. Bottom Line: Let's stop the damn witch hunts NOW and start focussing on positive things - like a winning season and how great U-M is! Go Blue!

Cheergirl

Tue, Sep 1, 2009 : 2:49 p.m.

Hey gang....I'm not an elite Ann Arborite...just a fourth generation graduate who is extremely proud and loyal. That said, as HMan stated all the incidents surrounding RR alone may not be much..but together they are looking like a pattern and bad omen. This coach is representing THE winningest football program in NCAA history which represents the best in collegiate sports ( not to mention the elite academics.) Therefore, our expectations of the coach are very high and should be. His job is really as good as it gets...and he does not fit the bill. Lots of people can coach football-the hard part is getting a leader who earns the respect of the players, coaches and fans, develops young men, sets the right example. RR is completely out of his league. RR IS the face of U-M to many people who watch TV sports and read the paper....and to me he is representative of where the U-M athletic program has been heading since Bill Martin took the helm. Did we win a national championship in any sport last year? This is not the first bad hire Bill M. has made...he may be a good businessman but he does not have the vision, creativity and sports mind of a Don Canham for example. My daughter is a recruited athlete at UNC-Chapel Hill. In the last several years, they have won national championships in women's soccer, women's softball, men's basketball, men's lacrosse, men's baseball and so on. Their coaches are highly respected and popular with great student body and alum support. No scandals that I am aware of....Michigan has always stood for excellence in sport and academics-that is looking like a thing of the past. We need to cut our losses.....RR should go-and please take Bill Martin with you RichRod!

ProTechCPA

Tue, Sep 1, 2009 : 1:36 p.m.

The one constant with Rich Rod is his massive ego. That is why he refuses to accept responsibility for his actions and why he refused to adapt his flawed game plan in the face of adversity and why he ran from WVU when he blew his one and only opportunity to play for a national title. UM will rise again. That rise will only begin with the firing of Rich Rod. Failure to accept this fact proves nothing beyond denial. The bleeding has just begun.

javajolt1

Tue, Sep 1, 2009 : 1:22 p.m.

Yeah, really, RR does THAT all the time!!

treetowncartel

Tue, Sep 1, 2009 : 1:20 p.m.

Wow, somebody got sued for breach of a contract? I don't think this has ever happened in America before. This guy is awful. Why doesn't Ann Arbor.com do a story on how many breach of contract cases are currently in our federal court system.

javajolt1

Tue, Sep 1, 2009 : 12:07 p.m.

I don't think ALL of these things together are going on elsewhere. This is a little bigger than that. No doubt, there are 'things' going on everywhere, but what we have here is a constant drumbeat of MANY seeming unrelated issues with a single common denominator. By themselves, none are big enough to sink any ship, but taken together, the drip, drip, drip is getting louder. This is something we've not seen around here because past coaches have managed to keep it from boiling into the spotlight. This has nothing to do with where RR came from, or whether he's a "Michigan Man". I don't think all of the concern is driven be ONLY Les Miles boosters anymore. This is becoming a problem.

UMthicknthin

Tue, Sep 1, 2009 : 12:03 p.m.

This should be between his financial advisors and lawyers if he was hoodwinked on this deal. I guess when you're piling on, everything counts. By Friday, I expect a headline, "Sources allege on Aug 21, RR didn't brush his teeth before retiring for the evening", break me a give. We have 4 days until kickoff, I guess the intent is to completely demoralize the coach, team and university.

grandma

Tue, Sep 1, 2009 : 11:55 a.m.

Honestly, this is probably going on at every university to some extent. The bad thing for U-M is that the players ratted the coach out. There's obviously left over disgruntled players from the Carr regime. I think RR wants to improve them so badly and it hurts him that some players want him gone.

grandma

Tue, Sep 1, 2009 : 11:55 a.m.

Honestly, this is probably going on at every university to some extent. The bad thing for U-M is that the players ratted the coach out. There's obviously left over disgruntled players from the Carr regime. I think RR wants to improve them so badly and it hurts him that some players want him gone.

RudeJude

Tue, Sep 1, 2009 : 11:54 a.m.

Rich Rodriguez and Michigan Football are now synonymous. Deal with it. Does anybody realize all the great "Michigan Men" were not from Michigan? I'm talking Yost, Crisler, Schembechler. All from other parts of the country, other schools. They became Michigan Men once they arrived. I am guessing they didn't have a cabal organized against them when they arrived or else Michigan wouldn't be what it is today. Give the guy a fair shot, that said to both the media and the Anti-Coach Rod fanbase. Put it this way, the commitment to Coach Rodriguez has been made, specifically to the personnel on the team. If he goes and we move away from the Spread, how successful do you think Michigan will be over the next few seasons with these players, picked for their affinity to fit into a Rich Rodriguez spread offense? How will that affect recruiting if Michigan haphazardly heads into a new direction, before letting the efforts of our current direction come into fruition? I doubt the recruits out there, with all this negativity from the fanbase and general chaos, think of Michigan as the place to be right now. This muckraking by the media and your negativity and overzealous expectations are going to put Michigan Football into the ground. Give the guy a break. Let him deal with his off-field, personal, legal matters himself. End this non-sensical witch hunt now.

salineguy

Tue, Sep 1, 2009 : 11:42 a.m.

Since day one, this has been a train wreck. When Terrelle Pryor chose Ohio State and Ryan Mallett chose to leave (can't remember which came first), RR was in a huge hole. He had no players last year of consequence and the team, in a word, stunk. He did not do a good job coaching, was unprepared, did not adapt, and the record reflected all of the above. People need to wake up a bit - something is wrong with this team and this coach. Players don't normally leave en masse, players don't normally rat out their coach, coaches don't normally burn burn bridges at the school where he made his name, quality teams don't normally go in to a season with 3 sub-par quarterbacks vying for a job. An 0-2 start an the dude is history!

javajolt1

Tue, Sep 1, 2009 : 11:27 a.m.

Where are Mary Sue Coleman and Bill Martin in all of this? This ship is listing heavily to one side. It's getting to the point where a good season isn't going to change the fact that we have some serious integrity problems. Wake up! This transcends football! This is the linchpin for your University, alumni relations, your hospital, donations...it's the most visible part of what The University of Michigan is and does, and has been for 40+ years. You loose this one and anything else you do in your careers won't matter. Are you listening??

NoBowl4Blue

Tue, Sep 1, 2009 : 11:24 a.m.

This what was written by a fan in West Virigina. Sums everything up: :the ex-coach is such a man of character, mostly bad. who would have thought on the day he bolted for michigan that eventually fans would view it as a postive. what a combination of greed and ambition packaged in such a flawed individual. whatever happens in the future will be well earned, go rr

Salinegoblue

Tue, Sep 1, 2009 : 11:20 a.m.

Listen to what most of you are saying, sweep it under the rug, don't report it, get behind RR and hopefully the players will lie and cover the coaching staff. What type of values are we encouraging the student athletes to demonstrate when everyone is hoping they will lie to protect the coach and the university. The U of M is much more than football, the institution is a beacon for others to follow. The U of M football has never been this embarassed. If we are guilty, then RR should step up to the microphone and accept responsibility. There was a story on espn.com where it took one of their writers an hour and a half to confirm the Free Press article.

grandma

Tue, Sep 1, 2009 : 11:01 a.m.

I love it... blind support... "Michigan Men... Michigan fans".... that sound like a grade school roundup. You can support the school without supporting everything they do. Just listen to the way RR talks. He does not have the class needed for a Big Ten Team. Skipping over the specifics in yesterday's press conference and refusing to talk about any of the allegations reeks of guilt. Listen to his grammar... and then tell me how focused he is on the team's education. "We done nothin' wrong" Please!

BillMK

Tue, Sep 1, 2009 : 10:57 a.m.

What a mess. It does look like the guy got suckered, as did many other folks who wanted to be part of the American Dream. Reagan/Greenspan Edition 2.0. The only way to have avoided this kind crap is to have been willing to avoid private investment, and thereby have a lot less money than your peers. I chose to do this in my own life - I just didn't want to deal with this stuff. Too distracting. It was easy for me: I make less than other doctors but more than most professors anyway, and I have a modest lifestyle, and few expenses. Not everyone can or will make this choice. The baggage may catch up with RR, although a good season would make up for a lot. If it does get him, I think it will be very unfair. To the extent that the "elite of ann Arbor"(whoever they are) are involved, their role in this will not be forgotten. Actually, I suspect it's more likely be the "elite of Grand Haven" and the like, who are still P.O.'d that the rest of us aren't Calvinists;>. We'll see. As for: "...and it may result in Martin going down with him." No, that's not how it is. Martin can't go down. Martin became AD at the request of the U - he did not need or initially even want the job. He would have been MUCH better off financially sticking with his investments. He has done extremely well with respect to finances, development, and buildings. We'll see about the rest. As for RR himself, I am more inclined to accept the judgement of people I respect, who have spoken positively of him (Jerry Hanlon, Jon Falk, and, likely, Jeron Stokes' dad), than that of Comic Book Men posting on the internet. I am also pleased, as an academic, to see that, despite all the distractions, the team has a higher GPA than in the past - even if they have to practice a lot! Again, we'll see.

catfishrisin

Tue, Sep 1, 2009 : 10:57 a.m.

Bo...we miss you

jb82

Tue, Sep 1, 2009 : 10:41 a.m.

Another non story. Frankly, Rodriguez's financial investment portfolio is nobody's business. Who cares? Beat the crap out of Western on saturday and I will be happy!

DwightSchrute

Tue, Sep 1, 2009 : 10:38 a.m.

TXMaizenblue, Nobody but RR and Bill Martin are making a joke of Ann Arbor. The list is long and growing longer. But I say it is Bill Martin's fault just as much. He botched the hire by failing to get someone more attuned to the history at Michigan. RR's first mistake was going so far after Pryor and losing Mallett. That might not have happened if Martin had hired a different coach who believes in a passing game. As a result 3 QBs will play in the opener. That is a travesty.

A2D2

Tue, Sep 1, 2009 : 10:35 a.m.

Who would be better at UofM? L. Miles? J. Harbaugh? Let's let the football coach be the football coach - at least for the next 13 weeks or so. A 9-3 record versus a 4-8 record in 2009 would certainly make some headlines go away.

NoBowl4Blue

Tue, Sep 1, 2009 : 10:28 a.m.

Not surprizing is it people? There is a definate pattern here.

mgoblue1999

Tue, Sep 1, 2009 : 10:22 a.m.

By the time this is done the media should know the true story behind the Kennedy assination and where to to find Jimmy Hoffa.

BoulderLion

Tue, Sep 1, 2009 : 10:11 a.m.

All these 'isolated' incidents (buy out of old contract, players leaving, 3-9 season, potential NCAA violations, and this) are nothing big by themselves. But put them together all at once, and its a perfect storm brewing. RichRod has precious few chips in the bank with people around here, so his 'boat' is pretty small. Depending on how the team looks this year, he may not survive this storm...and it may result in Martin going down with him.

H Man

Tue, Sep 1, 2009 : 9:49 a.m.

Salinegoblue, ask yourself, would current running backs coach Fred Jackson (Former Loyd Carr running back coach)allow his son to play for a coach with no integrity? Fred's son (Huron High) is a current Michigan commit. Give Fred Jackson some credit. He is a good man and so is Rich Rod.

Wolvdoug

Tue, Sep 1, 2009 : 9:44 a.m.

Get off RR's back...So he has a lawsuit...Sounds like a victim of a Ponzi Scheme....The man responsible is sitting in jail awaiting trial......Those of you who think RR had bad advice or should've known better....I have 1 name....Bernie Madoff....Look how long that went on and how many prominent and famous people he duped. Time to let the powers that be do their job and investigate the Practicegate matter. Nothings been proven, let the man do his job and hopefully the guys respond with some wins.

maizenbluenc

Tue, Sep 1, 2009 : 9:31 a.m.

Salinegoblue - if you are any type of a real Michigan fan, you will stop mouthing off and get behind the team (including the coaching staff) NOW! Our team, and our program are being attacked on many fronts. We need to stand behind the program like true Michigan Men and Michigan Fans would, and should. You sniping about a real estate ponzi scheme, in light of the number of people who were taken by Bernie Madoff, un-ethical lenders and real estate agents, etc., and in light of the fact that the former financial advisor who I would bet Rich trusted so he could focus on football, and the promoter of the scheme who is currently awaiting trial, is just ridiculous. (In fact, I am not happy annarbor.com posted this story this week.) The best thing for our program is for our team to get back on their horse now, and win again. The only way for that to happen is for all of us to support the coaching staff. Otherwise, we could face years and years of fall out (like Alabama, like Oklahoma, like USC, like Notre Dame....) Think. do you really want that? So if you're a real Michigan Fan, Salinegoblue, stand up and cheer for the team. If not, go away. Go Blue, Beat Western!

javajolt1

Tue, Sep 1, 2009 : 8:57 a.m.

How about the point: Bill Martin is the man who takes the credit or responsibility for this gathering storm. Rich Rodriguez is dealing with enormous pressures created in large part...by Rich Rodriguez. A proud and honest football tradition is being jeopardized if not by misdeeds, then by a level of innuendo that is creating distraction, mistrust and low morale. You know: once the program has been completely run over by a bus, it's not like you flip a switch to make it all better again. How far does it go before somebody says, 'enough'?

Salinegoblue

Tue, Sep 1, 2009 : 8:53 a.m.

I'm not the elite in AA but I'm not a RR fan. I think the hiring was botched and Martin was desperate when he hired RR. Carr may have not have wanted Miles, the timing of his retirement was horrible, right before the BCS bowls. That prevented the U of M from hiring Miles. The one thing that is constant with RR in all his issues is that he never accepts any responsibility, it is always someone elses fault.

63Townie

Tue, Sep 1, 2009 : 8:49 a.m.

Damn this guy's got baggage.

H Man

Tue, Sep 1, 2009 : 8:42 a.m.

I agree with Txmaizenblue. The elite in Ann Arbor really do have it out for Rich Rod, it is pathetic. People who question his integrity should listen to the parents of current players. Parents such as Jeron Stokes father who spent a week going to practices and meetings. They love Rich because of his character and emphasis on education. He has handled himself with class with the media and is a good man and coach. I guarantee Michigan fans will deeply regret it if he is run out of town.

chill out

Tue, Sep 1, 2009 : 8:39 a.m.

He was one of multiple investors in an entity that defaulted on a loan, that's it. He's not committing crimes. This practice time thing is total garbage and includes voluntary time - he obviously cares about his players, and all of last years seniors could be complaining and they're not. If he went 9-3 last year instead of 3-9 nobody would be talking about this stupid stuff.

Txmaizenblue

Tue, Sep 1, 2009 : 8:09 a.m.

Good Grief...the elite in Ann Arbor really have it out for this man. What a sad commentary on that community. I know there are many that will jump on this like a mouse on cheese, but those of us from afar see things quite differently. You people are unwittingly making Ann Arbor look like a joke.

Pete Bigelow

Tue, Sep 1, 2009 : 7:33 a.m.

Editor's note: This story has been updated to reflect that the real-estate loan was made prior to Mike Wilcox becoming Rich Rodriguez's financial advisor and legal counsel.

SonofScoot

Tue, Sep 1, 2009 : 7:23 a.m.

Thank God UM has lots of lawyers around. This guy RRod is putting lots of them to work.

salineguy

Tue, Sep 1, 2009 : 7:03 a.m.

RichRod's lawyer is one busy guy. The 'loyalists' always seem to want to look at each of the individual incidents - the money and shredding issues at West Virginia, the transfers, the potential practice violations, and now this - and find a way to portray the guy as a victim or to blame someone else. He's not a victim. If this much trouble has followed the guy in 18 months, what does the next 18 months hold? Can't remember the last 3 coaches having this many issues, combined, over the last 40 years. He better get his act together soon or that story a while back about him being the next coach at Marshall might not be too far off.

tater

Tue, Sep 1, 2009 : 6:10 a.m.

Why doesn't www.valtechcondos.com even work? There is no website at that addy.

a2grateful

Tue, Sep 1, 2009 : 5:38 a.m.

"One of five guarantors..."... You would not believe the number of excellent developers and investors that have defaulted on loans in speculative real estate, regardless of Ponzi schemes.... This is more fallout from the bank collapse. It is common in every major city across the US. Single-unit condo purchasers no longer qualify for loans, or default on mortgages. Units stop selling. No demand equals no absorption, equals no way for projects to survive. Projects are halted. Properties are foreclosed. Guarantors are sued, receiving personal judgements against their names.... However, there is a viscious rush to judgement to want to blame the US real estate collapse on coach Rich Rodriguez, as well.... Why stop there? In my crystal ball I foresee an upcoming headline in the Detroit Free Press: Rich Rodriguez singlehandedly causes international banking collapse, driving world to the brink of depression.... Give us a break. Rich Rodriguez is one of five guarantors in one deal of an international real estate market collapse. There are thousands of honest and hardworking investors like him.... My condolences to coach Rodriguez and his family for the hardships they currently face. My condolences to the haters and spinners for having such miserable lives, that mudslinging and idiocy are your greatest joys.... There is a real story here. How many speculative commercial real estate projects have gone into foreclosure the past two years? How many existing commercial real estate projects have gone into foreclosure the past two years? The answers to these questions will likely face you, in a profound way, in the next year.

GoblueBeatOSU

Tue, Sep 1, 2009 : 4:50 a.m.

"Rodriguezs financial advisor, Mike Wilcox, released a statement through Michigan spokesperson Dave Ablauf late Monday, saying Rodriguez is the victim of a real-estate Ponzi scheme."...what a great financial advisor. This Wilcox guy got his client involved in a ponzi scheme...the whole point of a financial advisor is to avoid that kind of stuff...RR has to do a better job selecting the people he associates with.

teldar

Tue, Sep 1, 2009 : 3:55 a.m.

wow, the troll formerly known as salinegoblue is back..... as salinegoblue forget it andrew scott, this troll has been around for years using probably 20+ names. It apparently is most likely a female ND fan if you'll believe it and appears as MSU and WVU trolls as well.

andrewscott

Tue, Sep 1, 2009 : 2:14 a.m.

Hey Saline, what part of "We are evaluating legal actions and solutions since the promoter of the scheme is currently awaiting trial on criminal charges." did you not understand? This has absolutely nothing to do with his integrity.

Salinegoblue

Tue, Sep 1, 2009 : 1:59 a.m.

Will it ever end with this guy, what is it going to be next? We need to get rid of him and bring in someone with integrity.